Case Digest (G.R. No. 195549)
Facts:
Willaware Products Corporation v. Jesichris Manufacturing Company, G.R. No. 195549, September 03, 2014, Supreme Court Third Division, Peralta, J., writing for the Court. Before the Court is a Petition for Review on Certiorari under Rule 45 seeking to set aside the Court of Appeals Decision dated November 24, 2010 and Resolution dated February 10, 2011 in CA-G.R. CV No. 86744.Jesichris Manufacturing Company (respondent) sued Willaware Products Corporation (petitioner) in the Regional Trial Court (RTC), Civil Case No. C-19771, alleging unfair competition and praying for damages and a permanent injunction to enjoin Willaware from manufacturing and distributing plastic automotive underchassis parts resembling those of Jesichris. Jesichris alleged it had manufactured and distributed such plastic-made automotive parts since its registration in 1992, and that Willaware — previously a maker of plastic kitchenware whose office was physically near Jesichris — began making identical automotive parts after hiring some former Jesichris employees and selling the copied products to Jesichris’s customers at lower prices.
Willaware denied most allegations but admitted proximity and that some former Jesichris employees had been hired. Willaware pleaded that the parts were reproductions of original vehicle parts and conformed to vehicle specifications, that Jesichris had no patent or exclusive right over the use of plastic for such parts, and that other manufacturers openly sold similar parts.
After trial the RTC found for Jesichris, concluding Willaware deliberately copied Jesichris’s products and sold them to Jesichris’s customers; the RTC awarded P2,000,000.00 actual damages, P100,000.00 attorneys’ fees, P100,000.00 exemplary damages, and a permanent injunction barring Willaware from manufacturing the plastic-made automotive parts Jesichris produced. Willaware appealed to the Court of Appeals (CA).
The CA (in CA-G.R. CV No. 86744) affirmed with modification: it deleted the P2,000,000.00 actual damages award for lack of proof and instead awarded P200,000.00 as nominal damages, while maintaining the RTC’s awards of attorneys’ fees and exemplary damages. Willaware’s motion for reconsideration before the CA was denied in a February 10, 2011 Resolution. Willaware then filed the present Rule 45 petition to the Supreme Court.
Issues:
- Did Willaware commit unfair competition under Article 28 of the Civil Code?
- If there was no unfair competition, should moral damages and attorneys’ fees have been awarded?
- Was the CA’s substitution of nominal damages (P200,000.00) for the RTC’s award of actual damages proper despite alleged failure to establish rights?
- Does the absence or invalidity of intellectual property registration (copyright/patent) preclude relief under Article 28?
- Did Jesichris establish goodwill or other protectable commercial interests sufficient to ground its Article 28 claim?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)